MARINE FIRE SAFETYObjectives:1. The International framework for standards on fire protection.2. Commonwealth Legislation3. State Legislation – how it relates to Commonwealth and between States4. Developing appropriate standards for coastal vessels – the NSCV5. Typical fire safety systems
International Maritime Organisation• The International Maritime Organisation (IMO) is a UN body dealing with marine safety.• The IMO develops a range of codes / standards:• The IMO has: – General assembly (all countries) – Council (executive management) – Committees• In relation to fire safety, the Committee concerned is the Maritime Safety Committee (MSC)• The MSC has a fire protection sub- committee
IMO – Instruments• There is a hierarchy of standards produced by IMO: – Conventions ( SOLAS relates to fire) • These are adopted under particular criteria –eg SOLAS -entry into force requires acceptance by 25 States whose merchant fleets comprise not less than 50 per cent of the worlds gross tonnage – Circulars (specific advice / interpretation that is more detailed or refines a convention) – Circulars relating to fire safety are produced by the Maritime Safety Committee (MSC) • Eg MSC/Circ 776 – Guidelines for the approval of equivalent fixed gas fire extinguishing systems for machinery spaces and cargo pump rooms – Codes – eg the Fire Safety System Code – detailed specifications (eg fire extinguishers) – Codes – Fire Test Procedure Code – details of testing procedures for fire products
Commonwealth Legislation• The Australian Maritime Safety Authority (AMSA) provide input for Australia on technical standards developed by IMO• Once an IMO Convention comes into force, the Commonwealth makes legislation to enforce the convention.• Generally, Fire Safety comes under the Navigation Act 1912 and Marine Orders made under the Nav Act.
Marine Orders.• Marine Orders Part 15 simply says SOLAS is the standard to adopt.• It then flows on that all lesser documents under SOLAS (Circulars, Codes) become law under Marine Orders Part 15• SOLAS is primarily relevant to “ships” not boats• MO Part 15 says that the USL Code applies to vessels that are not “SOLAS” vessels. This relates to vessels up to 35 metres / 500GRT operating on intra and inter state voyages.
USL Code• There is a need for a different standard for smaller commercial vessels rather than SOLAS– this is the Uniform Shipping Law Code (USL Code)• The USL Code was made by the Australian Transport Council in the 1970’s. It is a watered down version of IMO and Classification Society rules that made practical rules for small coastal vessels.• All States were involved in formulating the USL Code, and once finalised, all States made legislation enforcing the USL Code.
Problems with the USL Code1. The formation of the USL Code did not include a review and update process so it became out of date.2. The Code was inflexible because it was highly prescriptive.3. The Code couldn’t deal with new designs, novel craft etc4. The Code is ambitious because it tries to deal with a large range of vessels under one set of rules.5. The Code is applied differently in States due to different interpretation of requirements.6. The Code is applied differently in States due to political, legislative and local requirements.7. This led to a Inter-Governmental Agreement in 1997 that agreed to review the USL Code using a new body called the National Marine Safety Committee.
The NMSC / NSCV• The NMSC is gradually overhauling the USL Code and developing a new document called the National Standard for Commercial Vessels (NSCV).• The NSCV is designed to be more flexible and not outdate immediately.• The NSCV covers not only vessel design but operator competency and safety management.
General philosophy of the NSCV1. Get to the heart of what is trying to be achieved in the standard.2. Set requirements for safety based on risk assessment principles and cost benefit analysis.3. Provide a performance statements (safety outcomes) that are the non-negotiable safety outcomes.4. Provide prescriptive solutions to meet the safety outcome but also accept “equivalent solutions” where an alternative means to the prescriptive measure can still meet the safety outcome.
The Fire Safety Section Development • NMSC appoint a project leader and reference group. • A discussion paper is distributed defining problems with existing standard and examining fire casualties and identifying causes. • A draft standard is produced based on discussion paper and responses and is finalised by reference group. • A Regulatory Impact Statement is developed which describes the impacts, benefits costs that the proposed new standard will cause. • The RIS and draft standard are distributed for general consultation. • The reference group will consider the comment and propose a final draft of the standard. • The standard must then be endorsed by the NMSC and the ATC • The standard then still means nothing until States adopt it into legislation!
Benefits of this approach:• New technologies / materials can easily be accepted without changing the law.• Novel craft and design features can be used without changing the law.• Stakeholders understand what the standard is trying to achieve.• The standard stays workable and flexible for longer periods without review.• The Standard makes realistic requirements based on evidence received during risk assessments.
Benefits of this approach• It provides a prescriptive solution that provides good guidance in most cases. This gives comfort to designers, builders and regulators. (Cheapest option also)• It allows for innovation providing a product, design or system can be rigorously proven to meet the safety outcome. This is the more expensive option and will only really be taken up where prescriptive solutions cannot be used or where large cost savings are derived from the alternative approach.
SAFETY OUTCOMES OF FIRE SAFETY STANDARD:1. Prevention of explosive combustion2. Control risks of spillage of flammable liquids3. Control risks of ignition by sources of heat or sparks4. Prevention of exposure to the smoke and heat of fire5. Prevent or delay the spread of fire6. Protection of essential systems7. Reliability of fire systems
Safety Outcome – eg Prevent or delay the spread of fireOption 1 – Deemed to Option 2 – You don’tsatisfy solution like the deemed to(prescriptive) satisfy solution , so youEg You shall have either a are free to devise andHalon or CO2 fire rigorously prove anextinguishing system alternative approach that achieves the safetyProblem with USL Code – outcome.Halon was banned andonly left CO2 systems. For example “Pyrogen”These were inappropriate style fire systems arefor some vessels. being properly testedRegulators ended up and will meet themaking ad-hoc / requirements of theinconsistent decisions. standard in a structured way
HOW IS RISK ACCOUNTED FOR?Studies found fire risk (both probability and consequence) related to:1. The nature of the space on the vessel – engine rooms and galleys have highest incidence of fire. Larger engine rooms are a greater risk/2. The nature of the vessel operation – tankers and passenger carrying vessels have far higher consequence if fire occurs.3. Distance from Coast determines the level of external support that can be relied upon. Vessels operating further from the coast need to have better fire safety.
Vessel Risk Categories–Four fire risk categories are defined as follows— »Fire Risk Category I (lower risk) »Fire Risk Category II (moderate risk) »Fire Risk Category III (higher risk) »Fire Risk Category IV (highest risk)
Class of vessel Class A Class B Class C Class D Class E Unlimited Offshore Restricted Partially Smooth domestic operations offshore smooth waters operations operations waters Class 1 length of vessel < 35 m <35 m All lengths All All lengths lengths Class 1: 13 to 36 day pax III II II I I Class 1: 37 to 450 day pax III III II II IIClass 1: 451 & more day pax IV IV III III IIClass 1: 13 to 36 berthed pax III III II II II Class 1: 37 & more berthed IV IV III III III pax Class 2—Length of vessel < 35 m All lengths All lengths All All lengths lengths Class 2 Fire risk category II II I I I All lengths All lengths All lengths All All Class 3—Length of vessel lengths lengths Class 3 Fire risk category II II I I I
Risk categories of spaces on vessels1. High Risk2. Moderate Risk3. Accommodation Spaces4. Minor Risk5. Control Stations6. Escape and Evacuation routesWhere doubt exists or compartment is multi use – higher risk level applies
Space category Description1. High Fire Risk Spaces • Spaces where, without appropriate controls, the likelihood and consequence of fire are high. • Typically within such spaces, there is: • potential for the spillage or escape of potentially dangerous quantities of inflammable liquid or explosive vapour, and • the presence of one or more sources of heat or other sources of ignition. Examples- Machinery spaces with IC engines, boiler spaces, carriage dangerous goods, flammable goods. Limits are set on magnitude.
2. Moderate Fire • Spaces that Risk Spaces • contain potentially dangerous quantities of inflammable liquids but where the sources of ignition have relatively low frequency, or • contain heat sources or other sources of ignition but where the quantity or nature of material within the space to fuel a fire is such that the risk is significantly reduced, orExamples – Low power machinery spaces, electricalswitchboard rooms, galleys, fuel pumping equipment etc
3. Accommodation •Spaces that are likely toSpaces contain persons who: •are unfamiliar with the vessel, •may be asleep or disoriented at the time of an emergency, or •may inadvertently or deliberately initiate a fireExamples – sleeping rooms, mess rooms, pantries, toilets, public rooms
Table 27 —Fire-fighter’s outfits for sea-going vessels Fire risk Class A, B and C2 vessels category Minimum Minimum number of number of spare outfits charges I N/A N/A II N/A N/A III 31 31 IV 31 31KEY:1.Two sets are for the use of a rescue party. The third isavailable for backup person should the rescue party get intodifficulties.2.It is assumed that vessels operating in sheltered waters willhave ready access to shore-based fire fighting personnel, seePart A of this standard for guidance on safety obligations andPart E for emergency preparedness.
Table 7 — Structural Fire Protection for Fire Risk Category I High fire Moderate Accom- Minor Control EscapeCategory risk fire risk modation fire risk Stations andof space spaces spaces spaces spaces evacuati on routes. 1 2 3 4 5 6 30 ST ST ST STHigh fire STNF 301 30 1,3 301 301 2 risk 1 30 1, 2 30 1spaces Nil Nil Nil NilModerate STNF Nil Nil Nil Nilfire risk 2 STNF spaces